Corrective Action Plans

Browse how organizations respond to audit findings

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1. Termination of responsible parties
1. Termination of responsible parties
• The Employee responsible for overriding the internal controls and improperly authorizing disbursements without sufficient documentation was terminated from employment by the board of directors on April 2, 2026.
• The Employee responsible for overriding the internal controls and improperly authorizing disbursements without sufficient documentation was terminated from employment by the board of directors on April 2, 2026.
2. Mandatory Disclosures
2. Mandatory Disclosures
• In accordance with 2 CFR 200.13 on April 2, 2026, the organization notified its Federal Awarding Agency in writing of the audit finding and on April 6, 2026 a “Grant or Contract Fraud Complaint” was file with the U.S. Department of Health and Human Services Office of Inspector General.
• In accordance with 2 CFR 200.13 on April 2, 2026, the organization notified its Federal Awarding Agency in writing of the audit finding and on April 6, 2026 a “Grant or Contract Fraud Complaint” was file with the U.S. Department of Health and Human Services Office of Inspector General.
3. Strengthening Documentation Requirements
3. Strengthening Documentation Requirements
• Implement standardized documentation checklists for all disbursements
• Implement standardized documentation checklists for all disbursements
• Require complete supporting documentation prior to payment approval
• Require complete supporting documentation prior to payment approval
4. Enhanced Review and Approval Process
4. Enhanced Review and Approval Process
• Establish formal pre-payment approval workflows
• Establish formal pre-payment approval workflows
• Require documented supervisory approval for all expenditures
• Require documented supervisory approval for all expenditures
• Implement secondary review for federally funded transactions
• Implement secondary review for federally funded transactions
5. Segregation of Duties
5. Segregation of Duties
• Reassign roles to separate authorization, processing, and reconciliation functions
• Reassign roles to separate authorization, processing, and reconciliation functions
• Implement compensating controls where staffing limitations exist
• Implement compensating controls where staffing limitations exist
6. Staff Training and Compliance Education
6. Staff Training and Compliance Education
• Provide mandatory training on Uniform Guidance (2 CFR Part 200)
• Provide mandatory training on Uniform Guidance (2 CFR Part 200)
• Conduct annual refresher training for all relevant staff
• Conduct annual refresher training for all relevant staff
7. Review of Questioned Costs
7. Review of Questioned Costs
• Conduct a detailed review of all identified transactions
• Conduct a detailed review of all identified transactions
• Determine allowability in accordance with federal requirements
• Determine allowability in accordance with federal requirements
• Reimburse the federal program for any unallowable costs
• Reimburse the federal program for any unallowable costs
8. Monitoring and Oversight
8. Monitoring and Oversight
• Implement periodic internal audits of disbursement activity
• Implement periodic internal audits of disbursement activity
• Establish ongoing management review and compliance monitoring
• Establish ongoing management review and compliance monitoring
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